CAP Strategic Plans on Climate, Environment – Ever Decreasing Circles

The latest effort at CAP reform from the Commission was supposed to focus on a new delivery model, more environmental ambition, and a performance and monitoring evaluation framework. As the Croatian presidency ends, little progress has been made. In fact, as our CAP Strategic Plans project shows, in many cases, things have gone towards another direction. Matteo Metta reports.

This analysis is based on focus group meetings with national civil society organisations involved in the preparation of CAP Strategic Plans in the Member States, and follows up previous publications about criteria to check the level of environmental and climate ambition and CAP compliance with the European Green deal.

The preparations of CAP Strategic Plans

At Member State level, preparatory activities proceed in line with the progress made in the Council. The following general trends, explained in more detail in our CAP SP series, have been observed:

  • Drafting of generic SWOT analyses and assessment of needs (wish lists), which do not express any quantitative/qualitative commitments, leaving room for designing the CAP interventions and budget allocation regardless of (stated) evidence and facts. It seems that Member States are avoiding making themselves accountable in these preparatory phases, which can ultimately be useful to make cosmetic changes in the CAP Strategic Plans.
  • Low transparency and restricted stakeholder involvement, with limited considerations given to the recommendations advanced by civil society organisations in Ireland, Italy, Germany, Spain, Poland. In Germany, the associations of joint platform has advanced specific requests for the eco-schemes in the CAP Strategic Plan. In France, a report summarising the outcomes of the public debate has been published and sent to the Ministry of Agriculture. The report shows the prioritization of the CAP objectives according to the French citizens involved in the debate, as well as the suggestions for the new CAP Strategic Plans. An official reaction from the Ministry of Agriculture is expected soon. Similar proposals for a more sustainable CAP have been made in other countries, like Poland, Spain, Ireland, but with a few positive reactions or no answer at all. In all these attempts, there seems to be little space for a deeper policy shift. The highest power in shaping the CAP is still concentrated in the hands of the strong triple alliance: 1) agricultural ministries, 2) farmer unions, and 3) large food industries pushing for keeping ‘business as usual’. There is a growing feeling among progressive NGOs that the stakeholders involvement will be even lower when important decisions must be taken on the CAP Strategic Plans.
  • Low take up of the lessons learned and results of EIP-AGRI operational groups dealing with result-oriented agri-environmental and climate management (AECM) schemes. In this respect, Member States can be more serious and proactive in designing CAP interventions based on these innovative initiatives, which otherwise will remain only nice to read in magazines and newsletters instead of being approached to scale up and out into the wider agricultural sector.
  • Unclear decentralization of responsibilities in Member States with regional authorities like Italy, Germany, Spain, etc., especially with a view of designing more innovative and bottom-up interventions at regional level. Most likely in France, area-based measures, including AECM schemes, will be managed centrally by the national government, whereas the non-area-based measures will be delegated to the regional authorities. In Italy, Germany, Spain, rural development interventions will most likely be delegated to the regional authorities as it is in the current programming period. Does this represent a move away from the problematic ‘one-size-fits-all’ approach fomented by the politicians in Brussels?
  • Lack of serious proposals to reduce the administrative burden and improve the Farm Advisory Services, which will be essential to help farmers in meeting multiple CAP objectives.
  • Lack of initiatives or intense work to design ambitious eco-schemes and AECM with a bottom-up approach, which would include farmers, ecologists, environmental NGOs, civil society organisations, and ITC experts. On the other hand, we noticed an increase attention towards reconciling eco-schemes with ‘private sustainability schemes’, which are voluntarily adopted at farm level.

Some examples of private sustainability schemes are the High Environmental Value certification in France or the Glanbia Ireland Payment to boost biodiversity in dairy farms. Other examples were presented in the European Parliament to lobby/advise the Renew group.

While these initiatives are gaining ground on the assumption that the market can well manage and oversight the environmental sustainability of European farmers, there is currently no evidence or trusted systems in place to prove that this is true or even better than building an effective CAP control and performance system. There are also concern that these private schemes will result in an increase of administrative costs of CAP delivery in terms of double compliance check.

Furthermore, these schemes assume the well-functioning of ‘integrated point systems’ or ‘sustainability performance indicators’. The question is: will they really be less broken or more effective than the current public auditing, monitoring and evaluation of the CAP? Well, considering what is going on between the Commission, the Council and the Member States, and the challenges in building a serious control system and performance-oriented CAP, can we really expect something better from privately managed and certified eco-schemes – supported by public money?

The CAP reform at EU level

In our project on #CAP Strategic Plans, Arc2020 also follows the works in the Council. It might sound exaggerate but, as shown in the progress report about the last six months of Croatian Presidency, there has been little left of the initial Commission proposal for a CAP reform.

With the negotiations on the budget for the MFF 2021-2027 still ongoing, and the two-years transitional provisions almost agreed in the trilogues negotiations, there might be some opportunities to really reform the CAP. However, the progress made so far does not offers high hopes. Paradoxically, looking at points 16 to 20 about the Performance Monitoring and Evaluation framework (PMEF),  the progress report shows that we might even end up with a new CAP which is less performance oriented than the current one. Under the name of simplification, Member States are working hard to undermine the tools for the Commission to steer the policy along the programming period. Additionally, the report explains that Common monitoring and evaluation indicators might be finalised in delegated acts, instead of the basic legislation. The timeline and working procedures for completing this list are still uncertain.

Furthermore, the report shows how the Council is trying to:

  • Watering down the proposal for a more performance-oriented CAP, by drastically reducing the number of indicators subject to (now biannual) performance review or strongly weakening the policy mechanisms linked to the PMEF (e.g. postponing reporting timing, increasing flexibility for deviations to targets and milestones, excluding impact indicators from mid-term review).
  • Glossing over the compliance with the EU Green Deal, by delaying its robust integration into the current CAP Strategic Plans.
  • Weakening the control system and penalties in relation to enhanced conditionalities, leaving space for the Member States to deal with non-compliance in an already limited number of on-spot checks over the total CAP beneficiaries.

This article is produced in cooperation with the
Heinrich Böll Stiftung European Union.

Climate and environmentally ambitious CAP Strategic Plans: Based on what exactly?

How Transparent and Inclusive is the Design Process of the National CAP Strategic Plans?

European Green Deal | Revving Up For CAP Reform, Or More Hot Air?

Matteo Metta
About Matteo Metta 10 Articles
Matteo Metta is CAP Policy Analyst at ARC2020. He is specialised in agriculture, food, and rural development policy and evaluation. Matteo is a researcher on the digitalisation and its impacts on agriculture, forestry, and rural areas.